Morrison v. Olson

Under the Ethics in Government Act of 1978, a court-like body called the Special Division could appoint an independent counsel, removable only by the Attorney General for good cause, to investigate and prosecute high-ranking officials; Independent Counsel Alexia Morrison (plaintiff) investigated alleged obstruction and false testimony by Justice Department officials including Solicitor General Ted Olson (defendant). When Olson moved to quash Morrison's subpoenas as unconstitutional, the district court denied the motion and upheld the Act, but a divided court of appeals reversed, finding an independent counsel was a "principal" rather than "inferior" officer improperly appointed outside the Appointments Clause; Morrison appealed.